Last Updated: February 4, 2021
Colony Capital, Inc.: Privacy Notice
Below is a list of the sections included in this notice:
- Who We Are
- Information We Collect
- How We Use The Information We Collect
- Information We Share
- Record Keeping
- Your Choices
- How We Protect Personal Information
- Updates To Our Privacy Notice
- How To Contact Us
Who We Are
Information We Collect
Personal Information you provide
We obtain certain personal information (such as name and other contact details) directly from you when you fill in forms relating to your involvement in a fund, send us an email or otherwise communicate with us. The types of personal information we may obtain include:
- contact information, such as your name, postal address, email address, telephone number, facsimile number, online identifier, IP address, SSN, government identification number, social media handle;
- other personal information such as demographics, location information, online activities, financial information and health/biometric;
- details of your role with an organization that you represent and/or your involvement in a fund (including, if you are an investor (or potential investor), details of your investment of proposed investment);
- telephone number, email address, tax identification number, information regarding your work authorization status, work history, references, education history, employment history and professional designations; and other personal information about your qualifications. In addition, where legally permissible, you may provide information regarding your criminal history, gender, race/ethnicity, and your veteran and disability status; and
- where required for anti-money laundering purposes, background information such as your date and place of birth, the other details in your passport and information about criminal convictions.
Unless we explain otherwise at the time, providing personal information that we request is optional and any disclosures are made voluntarily.
Personal Information we collect from other sources
We may also obtain some limited information about you indirectly, for example when your colleagues give us your contact details and information about your role, or from publicly available sources such as the Internet and/or subscription based services.
How We Use The Information We Collect
We may use the information described above to:
- provide investor services to you, such as email alerts, newsletters and other communications;
- manage your (or the organization that you represent) investment in a CLNY fund;
- respond to and communicate with you about your requests, questions and comments;
- operate, evaluate and improve our business;
- perform data analyses and other processing;
- protect against identify theft and prevent fraud and other criminal activity (including through anti-money laundering checks), claims and other liabilities;
- manage and develop our relationship with you or the organization that you represent; and
- comply with and enforce applicable legal requirements, relevant industry standards and our policies.
We also may use the information we obtain about you in other ways for which we provide specific notice at the time of collection.
In some countries, we need to identify the legal basis upon which we process your personal information. In general, we can process your personal information lawfully because we have a legitimate interest in doing so, to pursue the purposes that we have set out above. We may also need to process your personal information in order to perform our legal obligations.
Information We Share
We also may disclose information about you (i) if we are required to do so by law, regulation or legal process (such as a court order or subpoena), (ii) in response to requests by government agencies, such as law enforcement authorities, (iii) for the purpose of or in connection with legal proceedings, or otherwise for the purpose of establishing, exercising or defending our legal rights, or (iv) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity. We also reserve the right to transfer any information we have about you in the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, dissolution, liquidation or other corporate event).
The disclosures of personal information referred to above include transfers of personal information which is subject to UK or European Union data protection laws to countries outside the UK, EU, the Cayman Islands Data Protection Law, California Consumer Protection Privacy (“CCPA”) and various other worldwide privacy regulations. CLNY is an international group of companies, headquartered in the U.S., and it has funds, affiliates and service providers, and relationships with counterparties and governmental authorities, all over the world. This includes transfers to countries, such as the U.S., which are not regarded by the European Commission as ensuring an adequate level of data protection. Where we transfer personal information subject to UK or European Union data protection laws to our service providers, other organizations involved in the management of the relevant fund or affiliated companies in those countries, we do so on the basis of data transfer agreements designed to protect the privacy of your information, in forms approved for this purpose by the European Commission.
The period for which we will keep your personal information varies depending on the information and how we obtained it. Personal information will not be held for longer that it is needed, given the purposes for which it is held. Further information regarding our record-keeping policies is available upon request.
How We Protect Personal Information
We take all reasonable precautions in accordance with applicable law, including implementing administrative, technical and physical safeguards, to protect your personal information against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use.
Updates To Our Privacy Notice
How To Contact Us
Colony Capital, Inc.
515 South Flower Street, 44th Floor
Los Angeles, CA 90071
Attention: Data Protection Team